Westmore · UDRP DecisionChlesi.com
The Panel ordered transfer of <chlesi.com> after finding all three UDRP elements established. The domain was an intentional misspelling of the CHIESI mark, replacing the letter “i” with “l”. The Panel found no evidence of rights or legitimate interests and determined that the Respondent registered the domain with knowledge of and intent to target the Complainant. Its use for a phishing email containing a false employment termination notice, its appearance on abuse blacklists, and the unanswered cease-and-desist letters supported the bad-faith finding.
The timeline behind chlesi.com
Registration, the decision and the archived record of what this domain actually displayed — from public RDAP and the Internet Archive.
Westmore reconstructs the full history behind chlesi.com — from public RDAP and the Internet Archive — as part of UDRP Intelligence:
This decision illustrates a combined typosquatting and email-impersonation pattern. Although the domain did not host an active website, its MX configuration and use for a false employment termination email supplied affirmative evidence of abuse. The Panel treated the single-character substitution, prior trademark rights, phishing conduct, blacklist appearance, and unanswered communications as mutually reinforcing evidence across the three UDRP elements.
Result of record. The panel's reasoning and decisive facts behind each element are in the Intelligence dossier below.
ARBITRATION AND MEDIATION CENTER ADMINISTRATIVE PANEL DECISION Chiesi Farmaceutici S.p.A. v. allegra harrison, Tire Service Center Company (TSCCO) Case No. D2026-0550 1. The Parties The Complainant is Chiesi Farmaceutici S.p.A., Italy, represented by Studio Barbero S.p.A., Italy. The Respondent is allegra harrison, Tire Service Center Company (TSCCO), Germany. 2. The Domain Name and Registrar The disputed domain name <chlesi.com> is registered with Name SRS AB (the “Registrar”). 3. Procedural History The Complaint was filed with the WIPO Arbitration and Mediation Center (the “Center”) on February 10, 2026. On February 10, 2026, the Center transmitted by email to the Registrar a request for registrar verification in connection with the disputed domain name. On February 11, 2026, the Registrar transmitted by email to the Center its verification response disclosing registrant and contact information for the disputed domain name which differed from the named Respondent (Protected Protected, Shield Whois) and contact information in the Complaint. The Center sent an email communication to the Complainant on February 12, 2026, providing the registrant and contact information disclosed by the Registrar, and inviting the Complainant to submit an amendment to the Complaint. The Complainant filed an amendment to the Complaint on February 16, 2026. The Center verified that the Complaint [together with the amendment to the Complaint/amended Complaint] satisfied the formal requirements of the Uniform Domain Name Dispute Resolution Policy (the “Policy” or “UDRP”), the Rules for Uniform Domain Name Dispute Resolution Policy (the “Rules”), and the WIPO Supplemental Rules for Uniform Domain Name Dispute Resolution Policy (the “Supplemental Rules”). In accordance with the Rules, paragraphs 2 and 4, the Center formally notified the Respondent of the Complaint, and the proceedings commenced on February 26, 2026. In accordance with the Rules, paragraph 5, the due date for Response was March 18, 2026. The Respondent did not submit any response. Accordingly, the Center notified the Respondent’s default on March 19, 2026. page 2 The Center appointed Taras Kyslyy as the sole panelist in this matter on March 26, 2026. The Panel finds that it was properly constituted. The Panel has submitted the Statement of Acceptance and Declaration of Impartiality and Independence, as required by the Center to ensure compliance with the Rules, paragraph 7. 4. Factual Background The Complainant is an Italian multinational biopharmaceutical company based in Parma, Italy, that develops and markets innovative therapeutic solutions for respiratory health, rare diseases and specialty care. The Complainant owns more than 5.643 international patents and is the third among Italian companies in all sectors in terms of number of patent filings. The Complainant has over 7.000 employees, operates in five continents with 23 direct subsidiaries and produces and distributes drugs in over 60 countries, with three production plants worldwide: in Parma, Italy, in France at La Chaussée-Saint-Victor and in Brazil at Santana de Parnaìba. The Complainant’s revenues for the first half of 2025 totaled 1.86 EUR billion. The Complainant owns numerous registrations of its CHIESI trademark in various jurisdictions, including for instance international trademark registration No. 1542645, registered on April 24, 2020 and European Union trademark registration No. 007216286 registered on May 11, 2009, also covering Germany. In order to protect and promote its CHIESI trademarks on the Internet the Complainant registered it as a domain name in numerous TLDs, including <chiesi.com>, registered on June 14, 2009. The website “www.chiesi.com” is the Complainant’s primary web portal for global promotion of its activities and products. The disputed domain name was registered on November 23, 2025 and does not resolve to any active website. The disputed domain name was used in the URLs of a website flagged as phishing and that it was also used for sending scam email communications. The disputed domain name had Mail Exchange (“MX”) records configured and an email address based on the disputed domain name was used to send a message providing a false employment termination notice. The Complainant sent cease and desist letters to the Respondent without further reaction from the Respondent. 5. Parties’ Contentions A. Complainant The Complainant contends that it has satisfied each of the elements required under the Policy for a transfer of the disputed domain name. Notably, the Complainant contends that the disputed domain name is identical or confusingly similar to the Complainant’s trademark. The disputed domain name is identical to the Complainant’s mark, except for the replacement of the letter “i” in the mark with the letter “l”. This single one-letter difference shall not prevent a finding of confusing similarity under the first element, considering users may not perceive the difference between the Complainant’s mark and the disputed domain name. This is a typical typosquatting case. As to the gTLD “.com”, it is merely instrumental to the use in Internet and shall be disregarded under the first element confusing similarity test. The Complainant also contends that the Respondent has no rights or legitimate interests in the disputed domain name. The Respondent is not a licensee, authorized agent of the Complainant or in any other way authorized to use the Complainant’s trademarks. Specifically, the Respondent has not been authorized to register and use the disputed domain name. In the absence of any license or permission from a complainant to use the Complainant’s trademarks, no bona fide or legitimate use of the domain name could reasonably be claimed. The Complainant is not in possession of, nor aware of the existence of any evidence demonstrating that the Respondent might be commonly known by a name corresponding to the disputed domain name as an individual, business, or other organization. The Respondent has not provided the page 3 Complainant with any evidence of use of, or demonstrable preparations to use, the disputed domain name in connection with a bona fide offering of goods or services before or after any notice of the dispute herein. The disputed domain name had MX records configured before the start of Complainant’s recovery activities, suggesting that the disputed domain name, highly confusingly similar to the Complainant’s trademark, was used for email communication purposes. Moreover, verifications carried out by the Complainant highlighted that the disputed domain name was used in URLs addresses identified as malicious by providers specializing in cyber threats identification and analysis. An email address based on the disputed domain name appears to have been used to send a message providing a false employment termination notice. Such use can never confer rights or legitimate interests, and it is neither a bona fide offering of goods or services nor a legitimate non commercial or fair use. Considering the composition of the disputed domain name, no fair use can be claimed. The CHIESI mark corresponds to the name of the Complainant’s founder and the term “chiesi” does not have any meaning in English language. Furthermore, no results could be found for “chlesi” on English dictionaries and on the WIPO Global Brands Database. Therefore, it is clear that the Respondent does not have any rights or legitimate interests in the disputed domain name, and that, in all likelihood, the Respondent registered the disputed domain name because of its close similarity to the Complainant's trademark CHIESI and to the Complainant’s domain name <chiesi.com>. In addition, the Respondent did not reply to the Complainant’s cease and desist letters. Finally, the Complainant contends that the disputed domain name was registered and is being used in bad faith. The Complainant’s mark is well-known, particularly in the pharmaceutical industry, due to its long- standing history as an international research-focused healthcare group specializing in the areas of respiratory, rare diseases, and special care. Searches for “chiesi” conducted on Google search engine return results exclusively related to the Complainant. The Respondent cannot credibly claim to have been unaware of the Complainant’s trademark at the time of registration of the disputed domain name. On the contrary, the Respondent was, or at the very least should have been, aware that its registration would be confusingly similar to the Complainant’s mark at the time of registration of the disputed domain name, particularly considering that the disputed domain name registration occurred only in November 2025. The composition of the disputed domain name itself, which reproduces a typosquatted version of the Complainant's trademark, strongly suggests that the Respondent was fully aware of, and deliberately intended to target, the Complainant and its trademark at the time of registration. The disputed domain name is highly similar to the main domain name used by the Complainant. The Respondent used the disputed domain name for malicious activities, specifically for phishing purposes. The non-use of the disputed domain name does not prevent a finding of bad faith under the doctrine of passive holding. B. Respondent The Respondent did not reply to the Complainant’s contentions. 6. Discussion and Findings A. Identical or Confusingly Similar It is well accepted that the first element functions primarily as a standing requirement. The standing (or threshold) test for confusing similarity involves a reasoned but relatively straightforward comparison between the Complainant’s trademark and the disputed domain name. WIPO Overview of WIPO Panel Views on Select UDRP Questions (“WIPO Overview 3.1”), section 1.7. The Complainant has shown rights in respect of a trademark or service mark for the purposes of the Policy. WIPO Overview 3.1, section 1.2.1. The applicable generic Top-Level Domain (“gTLD”) in a domain name (e.g., “.com”, “.club”, “.nyc”) is viewed as a standard registration requirement and as such is disregarded under the first element confusing similarity test. Thus, the Panel disregards gTLD “.com” for the purposes of the confusing similarity test. WIPO Overview 3.1, section 1.11.1. page 4 A domain name which consists of a common, obvious, or intentional misspelling of a trademark is considered by panels to be confusingly similar to the relevant mark for purposes of the first element. The Panel considers the disputed domain name consisting of intentional misspelling of the Complainant’s trademark. WIPO Overview 3.1 section 1.9. The Panel finds the first element of the Policy has been established. B. Rights or Legitimate Interests Paragraph 4(c) of the Policy provides a list of circumstances in which the Respondent may demonstrate rights or legitimate interests in a disputed domain name. Although the overall burden of proof in UDRP proceedings is on the complainant, panels have recognized that proving that a respondent lacks rights or legitimate interests in a domain name may result in the difficult task of “proving a negative”, requiring information that is often primarily within the knowledge or control of the respondent. As such, where a complainant makes out a prima facie case that the respondent lacks rights or legitimate interests, the burden of production on this element shifts to the respondent to come forward with relevant evidence demonstrating rights or legitimate interests in the domain name (although the burden of proof always remains on the complainant). If the respondent fails to come forward with such relevant evidence, the complainant is deemed to have satisfied the second element. WIPO Overview 3.1, section 2.1. Having reviewed the available record, the Panel finds the Complainant has established a prima facie case that the Respondent lacks rights or legitimate interests in the disputed domain name. The Respondent has not rebutted the Complainant’s prima facie showing and has not come forward with any relevant evidence demonstrating rights or legitimate interests in the disputed domain name such as those enumerated in the Policy or otherwise. The available evidence does not confirm that the Respondent is commonly known by the disputed domain name, which could demonstrate its rights or legitimate interests (see, e.g., World Natural Bodybuilding Federation, Inc. v. Daniel Jones, TheDotCafe, WIPO Case No. D2008-0642). The Complainant did not license or otherwise agree for use of its prior registered trademarks by the Respondent, thus no actual or contemplated bona fide or legitimate use of the disputed domain name could be reasonably claimed (see, e.g., Sportswear Company S.P.A. v. Tang Hong, WIPO Case No. D2014-1875). Panels have held that the use of a domain name for illegal activity here, claimed phishing/identity theft, can never confer rights or legitimate interests on a respondent. WIPO Overview 3.1, section 2.13.1. The Panel finds the second element of the Policy has been established. C. Registered and Used in Bad Faith The Panel notes that, for the purposes of paragraph 4(a)(iii) of the Policy, paragraph 4(b) of the Policy establishes circumstances, in particular, but without limitation, that, if found by the Panel to be present, shall be evidence of the registration and use of a domain name in bad faith. In the present case, the Panel notes that the Respondent registered the disputed domain name consisting of obvious and intentional misspelling of the coined trademark of the Complainant and used it for sending phishing email, which confirms the Respondent knew of the Complainant while registering the disputed domain name and targeted the Complainant and its trademark, which is bad faith. Panels have held that the use of a domain name for here, claimed phishing/identity theft, constitutes bad faith. WIPO Overview 3.1, section 3.4. Having reviewed the record, the Panel finds the Respondent’s registration and use of the disputed domain name constitutes bad faith under the Policy. page 5 The disputed domain name is listed on one or more blacklists indicating that it had previously been used in connection with spam, malware, or other domain name abuse activities, which confirms the bad faith use (see e.g., Instagram, LLC v. yusuf polat, schowix, WIPO Case No. D2021-2791). Moreover, the Respondent failed to respond to the Complainant’s cease and desist letters and did not provide any good reason to justify this, which confirms the bad faith (see, e.g., Compagnie Generale des Etablissements Michelin v. Vaclav Novotny, WIPO Case No. D2009-1022). The Panel finds that the Complainant has established the third element of the Policy. 7. Decision For the foregoing reasons, in accordance with paragraphs 4(i) of the Policy and 15 of the Rules, the Panel orders that the disputed domain name <chlesi.com> be transferred to the Complainant. /Taras Kyslyy/ Taras Kyslyy Sole Panelist Date: March 28, 2026
Source of record: WIPO . Reproduced for research; WIPO is the authoritative source.
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